1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: February

15, 2011 SUBJECT: Technical Support Document for Penns yl vania’s Adoption of Control Techniques

Guidelines for Flat Wood Paneling S urface Coating Processes /s/ FROM: Irene Shandruk, Phy sical Scientist

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning
A. BACKGROUND S ection 172(c)(1) of the Clean Ai r Act (CAA) provides that state implementation plans (SIPs) for nonattainment areas must include reasonabl y available control measures (RACM), including reasonabl y available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) provide s that for certain nonattainment areas, States must revise their SIPs to include RACT for sources of volatile organic compound ( VOC ) emissions covered b y a control techniques guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of attainment. The United States Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting b y the application of control technology

that is reasonably

available considering t echnological and economic feasibility .” (44 FR 53761, Sept. 17, 1979 )

. In subsequent Federal Register notices, EPA has addressed how states can mee t the RACT requirements of the CAA

. CTG s are intended to provide state and local air pollution control authorities information that should assist them in determining RACT for VOCs from various sources , including flat wood paneling surface coating processes . In developing these CTGs, EPA, among other things, evaluated the sources of VOC emissions from this industry and the available control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for VOCs from flat wood paneling surface coating processes

. In June 1978, EPA published a CTG for flat wood paneling coatings (EPA

- 450/2

- 78
- 034). Th is CTG discuss es the nature of VOC emissions from th is industry , available control technologies2

for addressing such emissions, the costs of available co ntrol options, and other items. EPA also publi shed a national emission standard for hazardous air pollutants (NESHAP) for surface coating of wood building products, including flat wood paneling in 2003 (40 CFR part 63, subpart QQQQ)

. In 2006 and 2007, after conducting a review of currentl y existing state and local VOC emiss ion reduction approaches for this industry , reviewing the 1 978 CTG and the NESHAP for th is industry , and taking into account the information that has become available since then, EPA developed a new C TG for surface coating of flat wood paneling, entitled Control Techniques Guidelines for Flat W

ood Paneling Coatings (Publication No. EPA 453/R

- 06
- 004). Description of Flat Wood Paneling Coatings Flat wood paneling coatings means wood paneling products that are an y interior, exterior or tileboard (class I hardboard) panel to which a protective, decorative, or functional material or layer has been applied. Flat wood paneling, like most wood products, are vulnerable to light, moisture and insects. Coatin gs are used for three purposes: protection, appearance, and surface modification. Surface coatings are applied to reduce potential damage from environmental elements such as moisture and temperature extremes and other climate

- related hazards and from ins ect infestation. Coatings are also applied to enhance surfaces to make other coatings more effective. Finally , coatings are applied to improve the appearance of the wood product. Releases of VOCs occur during the coating process as the coatings are mixe d or thinned, as they are applied to the substrate, and as they

dry and the VOCs within the coating evaporate into the air. Emissions of VOCs from flat wood coating facilities occur primaril y at the coating line, although some emissions also occur at paint mixing and storage areas. To assist facilities and regulatory agencies in estimating emissions, VOC emission factors for conventional solvent based coatings applied to interior printed panels are as follows (expressed as kilograms of VOCs per 100 square meters (m 2 ) coated): 3.0 for filler, 0.5 for sealer, 2.4 for basecoat, 0.3 for inks, and 1.8 for topcoats. EPA’s Recommended Control Options for Flat Wood Paneling Coatings EPA issued a CTG for flat wood p aneling c oatings in September 2006 (Publicatio n No. EPA 453/R

- 0 6
- 004). Recommendations for controlling VOC emissions from flat wood paneling coatings are outlined in the CTG and are as follows: The recommended emission limits for inks, coatings, and adhesives can be achieved either b y using material s with VOC contents low enough to achieve the limits during application, or b y reducing the amount of VOC emitted through the use of add

- on controls. There are two alternative limits recommended for the use of low VOC inks, coatings and adhesives. These limits are expressed in different units but are equivalent.3

A. Emissions L imits on Low

- VOC Coatings for Inks, Coatings and Adhesives : The low VOC materials recommendation for inks, coatings and adhesives include an emissions limit of 250 grams (g) VOC /l (2.1 lb VOC/gal) of material (minus water and exempt compounds). An equivalent limit, expressed as units of weight of VOC per volume of solids in all coatings is 350 g of VOC per liter solids (2.9 lb of VOC per gal of solids). The default VOC density used for making this conversion was 0.88 kg/l (7.36 lb/gal). B. Optional Add

- On Controls for Inks, Coatings and Adhesives : Should product performance requirements or other needs dictate the use of higher VOC coatings than specified above, a facility cou ld choose to use add

- on control equipment to meet an overall control efficiency of 90 percent. Add

- on devices include oxidizers and solvent recovery s ys tems, which coupled with their attendant s ys tems to capture the VOC being released at the affected faci lities, can achieve an overall control efficiency of 90 percent. This control option, like the low VOC material option noted above, applies to surface coatings, inks, and adhesives applied to all ty pes of flat wood paneling. C. Work Practices : Recomme nded work practices include steps to ensure that VOC emissions are minimized from mixing operations, storage tanks and other containers, and handling operations for coatings, thinners, cleaning materials, and waste materials. Examples of work practice standards include: storing all VOC coatings, thinners, and cleaning materials in closed containers, minimizing spills of VOC containing coatings, thinners, cleaning up spills immediately , conveying any coatings, thinners, and cleaning materials in closed containers or pipes, closing mixing vessels which contain VOC coatings and other materials except when specificall y in use, and minimizing emissions of VOC during cleaning of storage, mixing, and conveying equipment. Table 1 : Recommended Emission Limits for Flat Wood Paneling Operations Surface Coatings, Inks, or Adhesives Applied to the Following Flat Wood Paneling Categories Should Meet One of These Emission Limits lb VOC / gal ma terial ( g VOC/ liter material) [excluding water and exempt compounds] lb VOC / gal

solids (g VOC/ liter solids) Overall Control

Efficiency Using an Add - On Control Device Printed interior panels made of hardwood, pl ywood, or thin particleboard 2.1 (250) 2.9 (350) 90%
Natural finish hardwood ply wood panels 2.1 (250) 2.9 (350) 90% Class II finishes on hardboard panels 2.1 (250) 2.9 (350) 90% Tileboards 2.1 (250) 2.9 (350) 90% Exterior siding 2.1 (250) 2.9 (350) 90%4

B. STATE SUBMITTAL On January

4, 2011 , Pennsylvania Department of Environmental Protection (PADEP) submitted to EPA a SIP revision concerning the adoption of the EPA flat wood paneling surface coating processes CTG
. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. The Comm onwealth of Pennsylvania has adopt ed EPA’s CTG standards for flat wood paneling surface coating processes. These regulations are in 25 Pa. Code Chapter 121

— General Provisions and in Chapter 129

— Standards for Sources

. Specifically , this revision ame nds the existing regulations at §§ 121.1, 129.51 and 129. 66 , and adds new § 129.52 c . Section 129.52 c , which covers control of VOC emissions from flat wood paneling surface coating processes, supersedes the requirements of a RACT permit issued to the owner or operator of a source subject to § 129.52 ( c ) ( a) prior to January 1, 2012 under §§ 129.91

– 129.95 to control, reduce, or minimize VOC emissions from a flat wood paneling surface coating process, except to the extent the RACT permit contains more stringent r equirements. Chapter 121: General Provisions Section 121.1 : Definitions  Definitions for the following terms are added to support the addition of § 129.52c: “Class II hardboard paneling finish,” “decorative interior panel,” “engineered wood panel produc t,” “exterior siding,” “exterior trim,” “flat wood paneling coating,” “flat wood paneling product,” “hardboard,” “hardwood pl yw ood,” “MDF

— medium density fiberboard,” “natural

- finish hardwood pl ywood panel,” “particleboard,” “premium interior wall paneling product,” “pl ywood,” “printed interior panel,” “thin particleboard,” “tileboard” and “waferboard.” Chapter 129: Standards for Sources

– Sources of VOCs Section 129.51 : General  Section 129.51(a) is amended to extend its coverage to flat wood paneling surf ace coating processes . Section 129.51(a) also provides an alternative method for owners and operators of facilities to achieve compliance with air emission limits. Section 129.52 c : C ontrol of VOC emissions from flat wood paneling surface coating process es  This section includes VOC emission limits, work practices, and recordkeeping and reporting requirements, all of whic h are consistent with EPA’s CTG for flat wood paneling surface coating processes. The requirements in section 129.52 c supersede the requ irements in 129.52 relating to control of VOC emissions from flat wood paneling surface coating processes beginning January 1, 2012.  Subsection (a) establishes applicability for the emission limits

. The emission limits apply

to the owner or operator of a flat wood paneling surface coating process if the total actual VOC emissions from all flat wood paneling surface coating operations at the facility are equal to or greater than 15 pounds (6.8 kilograms) per day , before consideration of controls

.  Subsec tion (b) explains that the requirements of section 129.52 c supersede the requirements of a RACT permit from a flat wood paneling surface coating5 operation already issued to the owner or operator subject to section129.52 c unless the RACT permit contains mor e stringent requirements.  Subsection (c) establishes VOC emission limits which take effect beginning January 1, 2012. The emission limits are shown in Table 2. Table 2: Emission Limits of VOCs for Flat Wood Paneling Surface Coatings Surface Coatings, In ks, or Adhesives Applied to the Following Flat Wood Paneling Categories Should Meet One of These Emission Limits lb VOC/ gal coating solids g VOC/ liter coating solids Printed interior panels made of hardwood, pl ywood, or thin particleboard 2.9 350 Natural finish hardwood ply wood panels 2.9 350 Class II finishes on hardboard panels 2.9 350 Tileboard s 2.9 350 Exterior siding 2.9 350

 Subsection (d) establishes compliance monitoring procedures and identifies daily records that must be kept in order to demonstrate compliance.  Subsection (e) establishes recordkeeping and reporting requirements.  Subsection (f) explain s that VOCs may not be emitted into the atmosphere from the application of flat wood paneling surface coatings, unless the coatings are a

pplied using one or more of the following coating application methods: 1. Offset rotogravure coating 2. Curtain coating 3. Direct roll coating 4. Reverse roll coating 5. Hand brush or hand roller coating 6. High volume

—low pressure (HVLP) spray coating 7. Airless spray

coating 8. Air

- assisted airless spray coating 9. Electrostatic coating  Subsection (g) exempts coatings which are used exclusively for determining product quality

and commercial acceptance if the quantity of coating used does not exceed 50 gallons per year for a single coating and a total of 200 gallons per year for all coatings combined for the facility and if the owner or operator of the facility

requests this exemption in writing and PADEP approves, in writing, the exemption prior to use of the coating

.  Subsection (h) establishes work practice requirements for coating

- related activities.  Subsection ( i ) establishes work practice requirements for cleaning material s . Section 129 .66: Compliance schedules and final compliance dates  This section is amended by establishing a 1
- ye ar compliance date for owners or operators of a source newly subject to section 129.52, the existing surface coatings6 regulation, as a result of revised applicability requirements. The amendment is intended to ensure that this flexibility is extende d to owners and operators of sources newly subject to the expanding collection of surface coating regulations resulting from this CTG rulemaking , as well as three other CTG rulemakings, namely the large appliance, metal furniture, and paper, film and foil surface coating processes . The amendment will allow compliance for sources newly subject to the requirements within 1 year or b y the compliance date specified in the new regulation, whichever is later.
C. EPA EVALUATION PADEP has adopted the standards and requirements of the CTG for flat wood paneling surface coating processes and is amending the Pennsylvania SIP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readil y combine wi th nitrogen oxides (NO x ) to form ground

- level ozone. Specificall y, a maximum range of about 5 to 21 tons of additional annual VOC emission reductions are anticipated from the flat wood paneling surface coatings facilities in Pennsylvania as a result of th is rulemaking

. Therefore, this revision will help Pennsylvania attain and maintain the National Ambient Air Quality

Standards (NAAQS ) for ozone.
D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION The adoption of the EPA CTG requirements for flat wood pane ling surface coating processes by the Commonwealth of Pennsylvania will result in the reduction of VOC emissions from flat wood paneling surface coating processes . EPA ’s approval of the SIP revision is recommended.